Section 22 applies in respect of proceedings for the refund or recovery of tax paid or purportedly paid under a taxation law as if—
(a) a reference in section 22 to the Commissioner (except in subsection (2)(b)(ii)) were a reference to the court; and
(b) a reference in section 22 to the making of a refund were a reference to the making of an order or decision that a refund be made.
Part 5—Interest and penalty tax
Division 1—Interest